Lorenzo Harris was charged with murdering Larry Jones, who was shot in Atlanta. Before trial, the court excluded evidence of two other shootings and suppressed witness Ndetti’s identification after police showed her one photograph of Harris. One incident was a robbery after Jones’s death; the other occurred 19 days before it, and shell casings matched the same gun. The Supreme Court of Georgia held the State could appeal the oral rulings because the trial court effectively refused a timely request for written orders. It vacated both rulings and remanded. The trial court used the wrong Rule 403 test for the prior shootings: exclusion requires probative value substantially outweighed by unfair prejudice, not simply prejudice or greater prejudice than probative value. The court must reconsider admissibility under that standard. The single-photo display was impermissibly suggestive, but suppression also required a substantial likelihood of misidentification. Because the trial court did not adequately assess Ndetti’s prior familiarity with Harris, who had visited her apartment and left shortly before the shooting, the Supreme Court remanded for reconsideration under the correct reliability test without deciding admissibility.